US Toxics Packaging Certificate of Compliance Amended with New Declaration

Toxics in Packaging Clearinghouse (TPCH) has revised its sample Certificate of Compliance
with the inclusion of a new declaration relating to the use of chemicals to
replace regulated substances.

in 1989 by 19 US states, the Model Toxics in Packaging
Legislation outlines the basic requirements for disposable packaging. The
model states that the following four metals cannot intentionally be used above
the threshold level of 100 ppm (in sum):

  • Lead
  • Cadmium
  • Mercury
  • Hexavalent

the terms of the legislation, and other state laws, packaging suppliers,
product manufacturers, and/or distributors must issue a Certificate of
Compliance. This can be based on either the certificates of compliance issued
by the suppliers of each packaging component or an analytical test report covering
the four heavy metals in the packaging. Stakeholders must keep the Certificate
of Compliance on file, although the length of retention for the record is
dependent upon the individual state’s requirements.

Model Certificate of Compliance declares:

  1. “We
    certify that the regulated chemicals – lead, mercury, cadmium, and hexavalent chromium — were not intentionally added to any package or packaging component during the manufacturing process”
  2. “We further certify that the sum of the incidental concentration levels of lead, mercury, cadmium and hexavalent chromium present in any package or package component does not exceed 100 parts per million by weight”

April 2020, TPCH added the following declaration:

  • “We
    further certify that no materials used to replace the regulated chemicals are present in a quantity or manner that creates a hazard as great or greater than the hazard created by the regulated chemicals”

are now advised to check their products continue to conform to the declarations
in the sample Certificate of Compliance.

Packaging Services

is committed to providing information about regulatory developments in relation
to packaging. Their global network of laboratories provides physical/mechanical
testing, analytical testing, and chemical testing services, in addition to
consultancy work, to help manufacturers ensure their products conform to
national and international standards. Learn more about SGS Packaging

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The Toxics in
Packaging Clearinghouse Revises the Sample Certificate of Compliance

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For further information contact:

Hsin Chen

Technical Manager – Restricted Substances

Tel:+1 973 461 7950



LinkedIn: sgs-consumer-goods-&-retail


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